- 29 - The evidence before us discloses no reason for the original abatement of $867.92. On the contrary, the evidence justifies imposition of the late filing additions. Petitioner also contends that respondent conducted an unauthorized second examination of his books in violation of section 7605(b). Petitioner’s error arises from his misreading of the certificate of assessment and payments. This document indicates that the matter of petitioner’s 1995 tax liabilities was transferred without assessment from the IRS Examination Division to the IRS Appeals Office and then, when petitioner’s administrative appeal was unavailing, back to the Examination Division for the assessment of the taxes in issue. It does not show that there was an unauthorized second examination of petitioner’s books and records with respect to his 1995 taxable year. Our review of the procedures used in assessing and collecting petitioner’s Federal income tax liabilities supports the Appeals officer’s determination that the Notice of Federal Tax Lien should not be withdrawn. Petitioner has not shown that respondent erred in declining to invalidate assessments of Federal income taxes for 1995 or 1997. The assessments were made within the applicable period of limitations and were valid.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011